ML11188A175
| ML11188A175 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 06/23/2011 |
| From: | Repko R Duke Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RIN 3150-AG48 | |
| Download: ML11188A175 (5) | |
Text
Duke REGIS T.
REPKO Vice President Energy McGuire Nuclear Station Duke Energy MG01VP / 12700 Hagers Ferry Rd.
Huntersville, NC 28078 980-875-4111 980-875-4809 fax regis. repko@duke-energy. com June 23, 2011 10CFR50.48(c)
U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555
Subject:
Duke Energy Carolinas, LLC (Duke Energy)
McGuire Nuclear Station, Units 1 and 2 Docket Numbers 50-369 and 50-370 Request for Extension of Enforcement Discretion and Commitment to Submittal Date for 10 CFR 50.48(c) License Amendment Request
References:
- 1. SECY-11-0061, A Request to Revise the Interim Enforcement Policy for Fire Protection Issues on 10 CFR 50.48(c) to Allow Licensees to Submit License Amendment Requests in a Staggered Approach (RIN 3150-AG48), dated April 29, 2011
- 2. Staff Requirements Memorandum SECY-1 1-0061, A Request to Revise the Interim Enforcement Policy for Fire Protection Issues on 10 CFR 50.48(c) to Allow Licensees to Submit License Amendment Requests in a Staggered Approach (RIN 3150-AG48), dated June 10, 2011
- 3. Letter from McGuire Nuclear Station to Document Control Desk (NRC), dated January 16, 2009 In accordance with Reference 1, and as approved by the Commission per Reference 2, Duke Energy commits to submit the License Amendment Request (LAR) implementing 10 CFR 50.48(c) for the McGuire Nuclear Station by September 30, 2013.
The resources available to complete McGuire's LAR are presently dedicated to the preparation for the Oconee Fire Probabilistic Risk Assessment Peer Review as required by the Oconee NFPA 805 Safety Evaluation dated December 29, 2010. The Oconee Peer Review is scheduled for the fall of 2011. These same resources will then be used to incorporate the resolution of any issues developed as a result of that review for all three Duke Energy nuclear stations.
www. duke-energy corn
U.S. Nuclear Regulatory Commission June 23, 2011 Page 2 This is a change to the committed schedule submitted in Reference 3. This letter contains no new commitments and one revision to the existing commitment contained in Reference 3. Early resolution of issues developed as a result of the Oconee Peer Review may allow the McGuire LAR to be submitted prior to September 30, 2013.
McGuire undertook an Appendix R reconstitution effort in order to provide a basis for the transition to a fire protection program based on NFPA 805. The resulting risk reduction corrective actions are addressed in Attachment 1 to this letter.
In addition, Duke Energy requests that the enforcement discretion be extended to correspond to the LAR submittal commitment date. Per the enforcement discretion policy, once the LAR is submitted, the enforcement discretion will continue until the NRC dispositions the LAR to transition to NFPA 805, consistent with Reference 1.
Pursuant to 10 CFR 50.91, a copy of this request is being sent to the designated official of the State of North Carolina.
If you have any questions or require additional information, please contact K. L. Ashe at (980) 875-4535.
Very truly yours, R. T. Repko Attachment
U.S. Nuclear Regulatory Commission June 23, 2011 Page 3 Regis T. Repko affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.
RegiT. Repko, Vice President, McGuire Nuclear Station Subscribed and sworn to me:
Date AI C Notary Public My commission expires:
Dhte SEAL
U.S. Nuclear Regulatory Commission June 23, 2011 Page 4 xc (with attachment):
V. M. McCree Regional Administrator, Region II U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, GA 30303-1257 D. V. Pickett Senior Project Manager, Plant Licensing Branch, DORL U.S. Nuclear Regulatory Commission Mail Stop 0-8 G9A Washington, DC 20555-0001 R. P. Zimmerman Director, Office of Enforcement U.S. Nuclear Regulatory Commission Mail Stop 4 A15A Washington, DC 20555-0001 J. H. Thompson (addressee only)
NRC Senior Project Manager (McGuire)
U.S. Nuclear Regulatory Commission Mail Stop 0-8 G9A Washington, DC 20555-0001 J. B. Brady NRC Senior Resident Inspector McGuire Nuclear Station W. L. Cox III, Section Chief North Carolina Department of Environment and Natural Resources Division of Environmental Health Radiation Protection Section 1645 Mail Service Center Raleigh, NC 27699-1645
U.S. Nuclear Regulatory Commission June 23, 2011 Attachment I McGuire Nuclear Station, Units 1 and 2 NFPA 805 Transition Progress-Identified Risk-Significant Fire Protection Issues Duke Energy has made substantial progress in the McGuire Nuclear Station NFPA 805 transition effort. Duke Energy has participated in the NEI NFPA 805 Task Force, Fire PRA Task Forces, the Frequently Asked Questions (FAQ) process, and has made significant efforts in performing work activities in an effective manner, while utilizing the lessons learned from the Pilot Plant process. SECY-11-0061, dated June 10, 2011 states in part:
"Licensees must address all nonconforming conditions with adequate compensatory measures to ensure fire safety with sufficient defense in depth."
McGuire undertook an Appendix R reconstitution effort in order to provide a basis for the transition to a fire protection program based on NFPA 805. The resulting risk reduction corrective actions are discussed below:
Current Transformers: Current Transformers associated with a non-safety power monitoring system in the Turbine Buildings created a situation in which a fire could potentially disable both safety related trains of the respective unit. Modifications correcting this vulnerability were implemented within approximately 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
Pressurizer Heaters: Fire area conflict analysis determined that a control device in the circuit supplying assured electrical power to each of the two (2) Technical Specification required groups of pressurizer heaters received control power from a non-diesel generator backed power source. Modifications were promptly implemented to correct this situation on both units.
o Electrical Circuit Analysis: Fire area conflict analyses were conducted in each fire area including the consideration of unlimited "smart" hot shorts and the potential for motor operated valve operator damage (USNRC Information Notice 92-18). Extensive fire watches have been implemented since 2009 to address these newly discovered vulnerabilities in order to comply with the current licensing basis. A feasibility evaluation of manual operator actions was performed utilizing the guidance provided in NUREG-1852.
o Hemyc Fire Wrap: The installed Hemyc fire wrap (USNRC Generic Letter 2006-03) in the turbine driven auxiliary feedwater pump rooms of both units is presently considered inoperable with on-going fire watches.
Final resolution of these open issues may occur as a result of procedure changes, modifications or NRC approval of the McGuire NFPA 805 license amendment request.
The non-cited violations identified during the 2009 NRC Triennial Fire Protection Inspection (ML091801050) have been corrected.
Additionally, the administrative documents associated with plant configuration changes have been revised to address both current and future (NFPA-805) requirements.
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